CASS (FAR 121.373): Frequently ignored . . . source of violations

CASS (FAR 121.373) Frequently ignored . . . source of violations By Stephen P. Prentice Some big name brand airlines have recently been nailed for failing to implement or maintain an active Continuous Analysis and Surveillance System...

Typically, a CASS will involve an audit function, a monitoring function, a review function, and a correction process. All mechanics, technicians, and administrative personnel provide the data for analysis of these functions.

The management team involved with the CASS will look at the following data among others, and any significant occurrences:

  1. Pilot reports
  2. Continuous maintenance findings
  3. Mechanical performance data
  4. Mechanical reliability reports
  5. Delay reports
  6. Tear down reports
  7. SIDs, inspection checks, other timed items
  8. Special inspection reports
  9. Vendor and agency audits

This is not brain surgery but does require a management staff to coordinate and collect the data required for the analysis. Publishing a monthly summary report that complies with the FAA requirements is a major task. CASS reports now are also a fertile source for FAA Letters of Investigation (LOI's) and subsequent violations simply because they provide inspectors with so much data and may include facts that are incriminating and form the basis for a violation. Although certificate action is available, civil penalties are much more the norm and the fines are significant.

Somebody has to manage such a program and in the usual case the chief inspector or director of safety is charged with the duty of organizing and managing the meetings. A separate manager of CASS is typically required where the size of the carrier calls for additional staff. The CASS staff should be considered independent and free to do their work without undue influence from other personnel or departments.

Technicians should be included from the various maintenance departments, including line and shop facilities. Many times the president of the airline or his immediate assistant will attend a CASS meeting in order to lend support to its importance. Many companies make it an all day affair away from the normal workplace in order to minimize distractions.

The CASS manager and the chief inspector or director of maintenance and the chief pilot, or their representatives, should review, among other items, a summary of discrepancy reports for all fleet aircraft. These reports are routinely available on computer printouts. The key here is to highlight areas of concern and look for failure trends. All discrepancies and corrective measures taken should be reviewed on a monthly basis and action outlined for continued surveillance and or corrective action. Needless to say, a repeating discrepancy gets special attention.

A quality improvement program is included in any discrepancy solving equation. Improvements to the basic process should be designed and applied along the lines of a quality program like Six Sigma and similar improvement protocols.
All fleet deferred maintenance items (DMIs) should be reviewed and examined for excessive repeat items. A basic quality assurance program should be assigned to the DMI solution.

Internal audit (evaluation)
An audit is a methodical, planned review that determines how business is being conducted and compares results with how business should have been conducted in accordance with established procedures.

Internal audits are integral and essential to the CASS. This audit function is not to be confused with the Internal Evaluation Program described under AC-120-59 (Air Carrier Internal Evaluation Programs). This internal evaluation program should not be considered to be a program that replaces the auditing requirements of CASS. Audits are a small part of an internal evaluation program. There is however a significant difference between the two. Whereas the FAA has access to all data from the CASS, internal evaluation data is proprietary and need not be available to the FAA. Internal evaluation is a voluntary program at this time and is not a substitute for the CASS.

When substantial violations are found by either system before the FAA is involved, a self-disclosure procedure can be followed to attempt to avoid a violation. Self-disclosure is a procedure that is relatively new. It should be used with great caution however because it can still result in action against the carrier. Be aware, there is no guarantee that the FAA will not issue a violation even after a self-disclosure procedure is completed and accepted. Many a chief inspector regrets filing for a self-disclosure after finding out it was not accepted. And there is no taking it back! Once a self-disclosure is made it can be the subject of a certificate action or civil penalty action and of course you have just entered a guilty plea in most cases!

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